Preparing for NESHAPS Regulations

NESHAP Metal Fabrication and Finishing Regulations

In this era of expanding environmental awareness, it’s not surprising that the U.S. Environmental Protection Agency set in motion regulations for controlling air emissions for metal fabrication and finishing. Issued in 2008, the EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Metal Fabrication and Finishing impacts the way many firms complete their work.

Characterizing a company or business as a source of hazardous air pollutants is actually the first step toward compliance. It’s also generally considered an easy first step. Scan the nine metal fabrication and finishing source categories defined by the EPA to determine if your manufacturing operations fall within the definition. The key differentiator to focus on is whether any of these categories are a primary production operation.

Characterizing a company or business as a source of hazardous air pollutants is actually the first step toward compliance. It’s also generally considered an easy first step. scan the nine metal fabrication and finishing source categories defined by the EPA to determine if your manufacturing operations fall within the definition. The key differentiator to focus on is whether any of these categories are a primary production operation.

The nine categories include:

(1) Electrical and Electronic Equipment Finishing Operations
(2) Fabricated Metal Products
(3) Fabricated Plate Work (boiler shops)
(4) Fabricated Structural Metal Manufacturing
(5) Heating Equipment, except Electric
(6) Industrial Machinery and Equipment Finishing Operations
(7) Iron and Steel Forging
(8) Primary Metal Products Manufacturing
(9) Valves and Pipe Fittings

Even more specifically, there are five primary processes common to the nine categories that are considered likely to emit Metal Fabrication Hazardous Air Pollutants (MFHAP). These include: dry abrasive blasting; dry grinding and dry polishing with machines; machining; spray painting; and welding.

What is Considered a MFHAP?

A metal fabrication potential pollutant is any compound of the following metals: cadmium, chromium, lead, manganese, or nickel, or any of these metals in the elemental form, with the exception of lead.

How do you determine if your activity meets the definition of primary production operation?

The EPA defines a primary activity as one where the manufacturing, fabrication or forging operations at a single facility are comprised of at least 50% of the production of that facility in one of these nine categories and five processes. If you and your industry define production in terms of volume, linear or square foot or other terms, you would use those terms to define the 50% threshold.

Who does this regulation affect?

In many cases, large manufacturers are already regulated through an EPA regulation called MACT and are considered a major source of hazardous air pollutants. Metal fabrication hazardous air pollutants are a subset of these. The EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) affects many small to medium sized businesses. This rule applies to those businesses the EPA defines as an area source, rather than a major source. An area source is considered an operation that has the potential to emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of multiple hazardous air pollutants.

Specifically, when it comes to welding operations, businesses have requirements based on annual pounds used of any particular welding rod or wire. If your business annually uses 2000 lbs or less, you will have welding management and record keeping requirements. If you annually use more than 2000 lbs of welding rod or wire, you will be required to perform certain emissions monitoring as well as the welding management and record keeping requirements.

Does this affect a certain industry more than others?

The Clean Air Act contains a list of 188 chemicals that are officially classified as hazardous air pollutants. As this pertains to welding, Lincoln Electric has identified the following AWS specifications which contain consumables that have hazardous air pollutants:
• A5.1/A5.1M:2004 Carbon Steel Electrodes for Shielded Metal Arc Welding
• A5.2/A5.2M:2007 Carbon and Low Allow Steel Rods for Oxyfuel Gas Welding,
• A5.4/A5.4M:2006 Stainless Steel Electrodes for Shielded Metal Arc Welding
• A5.5/A5.5M:2006 Low Alloy Steel Electrodes for Shielded Metal Arc Welding
• A5.6/A5.6M:2008 Copper and Copper-Alloy Electrodes for Shielded Metal Arc Welding
• A5.7/A5.7M:2007 Copper and Copper-Alloy Bare Welding Rods and Electrodes
• A5.8/A5.8M:2004 Filler Metals for Brazing and Braze Welding
• A5.9/A5.9M:2006 Bare Stainless Steel Welding Electrodes and Rods
• A5.11/A5.11M:2005 Nickel and Nickel-Alloy Welding Electrodes for Shielded Metal Arc Welding
• A5.13:2000 Surfacing Electrodes for Shielded Metal Arc Welding
• A5.14/A5.14M:2009 Nickel and Nickel-Alloy Bare Welding Electrodes and Rods
• A5.15-90 Welding Electrodes and Rods for Cast Iron
• A5.16/A5.16M:2007 Titanium and Titanium-Alloy Welding Electrodes and Rods
• A5.17/A5.17M-97 Carbon Steel Electrodes and Fluxes for Submerged Arc Welding
• A5.18/A5.18M:2005 Carbon Steel Filler Metals for Gas Shielded Arc Welding
• A5.20/A5.20M:2005 Carbon Steel Electrodes for Flux Cored Arc Welding
• A5.21:2001 Bare Electrodes and Rods for Surfacing
• A5.22-95 Stainless Steel Electrodes for Flux Cored Welding and Stainless Steel Electrodes for Gas Tungsten Arc Welding
• A5.23/A5.23M:2007 Low Allow Steel Electrodes and Fluxes for Submerged Arc Welding
• A5.25/A5.25M-97 Carbon and Low Alloy Steel Electrodes and Fluxes for Electroslag Welding
• A5.26/A5.26M-97 Carbon and Low Alloy Steel Electrodes for Electrogaws Welding
• A5.28/A5.28M:2005 Low Alloy Steel Filler Metals for Gas Shielded Arc Welding
• A5.29/A5.29M:2005 Low Alloy Steel Electrodes for Flux Cored Arc Welding
• A5.30/A5.30M:2007 Consumable Inserts
• A5.34/A5.34M:2007 Nickel-Alloy Electrodes for Flux Cored Arc Welding

What will I have to do if this applies to me?

You will need to produce supporting documentation. Regarding proper operation of equipment, you will be required to produce documentation that you are operating and maintaining the equipment to the manufacturer’s specification.

Regarding the welding management plan requirement, you will have to show that one or more welding practices have been implemented to minimize welding emissions of MFHAP while maintaining welding quality. You can use one or more of several prescribed methods, including adopting alternative welding processes, selecting alternative filler metals or shielding gases, optimizing your procedures and / or adding fume control systems.

Seeking Help

Lincoln Electric, as a supplier of fume exhaust equipment, is working to ensure manufacturers are aware of the EPA MFHAP – NESHAPS rule. As such, the firm cannot directly assist a fabricator with their compliance efforts regarding this regulation. However, Lincoln Electric can act as a reference to assist fabricators to gather the right materials, identifying potential solutions in a welding management plan and periodically conduct informal audits of welding fume solutions in place to suggest paths for improvement to allow the fabricator to adhere to these regulations.

In some cases, a welding process change and the use of a weld fume control solution can be part of this plan. In other cases or situations, welding procedural development may be required, in the form of recommendations for different welding electrodes, wire or shielding gases.

In any case, it is an urgent matter for fabricators to learn more about these regulations, determine what their path will be, seek help if necessary and begin filing the appropriate documentation. Delaying will only make the effort more difficult.

Fabricators should be aware that resources are available for their use.

This summary of governmental regulations is provided for informational purposes only. Customers should consult with legal counsel in order to determine which regulations apply to their operations and what must be done to comply with those regulations.